by Ghassan Zughaib
In October 2019, the GSO (GCC Standardization Organization) published its first draft (GSO/TC01) for implementing the Globally Harmonized System (GHS) in the GCC countries based on the 5th revision of GHS. The draft is available on the GSO website at https://www.gso.org.sa/en/. The Gulf countries that are members of GCC include Saudi Arabia, United Arab Emirates (UAE), Kuwait, Qatar, Bahrain, and Oman. The implementation will help the competent authorities align more closely with other countries who have fully implemented GHS. At the point of writing this article, there are no Chemical Inventories in the 6 countries forming the GCC.
The new implementation of the Globally Harmonized System is expected to happen by mid-2020. After the implementation of GHS, there will be a grace period of 2-3 years for the six countries in the GCC to place the new law in their legislation, giving all companies who do business in that region enough time to adjust to the new regulation.
The draft liberally refers to the EU CLP as its model thus referencing concepts such as SVHCs and makes the same distinction as CLP between cut-off values and concentration limits.
Some key points from the draft:
- The Safety Data Sheets (SDS) will include the standard 16 sections, and will be written in both Arabic and English. The SDS information should be updated regularly and if no new information become available they will need to be reviewed once every 3 years at minimum. If it becomes necessary to update the SDS, it should be revised without delay with the revised version of the SDS provided to all who have purchased the product within the preceding 12 months.
- Confidential Business Information (CBI) will be allowed to protect trade secret materials without compromising any risks to human health or the environment. Any CBI information shall be given to the competent authorities if requested.
- Labels will be also be in Arabic and English, with a maximum of 6 precautionary statements on the label, unless it is necessary to include more due to the severity of the hazards of the product.
- Classification will be based off the Annex VI of the EU CLP regulation and is considered a mandatory classification. However, this is considered a minimum classification and the responsible party must additionally self-classify for those hazard classes not covered in the Annex VI entry. It is unclear in this draft as to which CLP adaptation will be mandatory as chapter 8 of the draft refers to the 9th ATP while the Appendix (Resources) refers to the 11th
- The excluded building blocks match those excluded by the EU CLP regulation: Flammable liquid category 4; Acute toxicity category 5; Skin corrosion/irritation category 3; Serious eye damage/eye irritation category 2B; Aspiration hazard category 2; Hazardous to the aquatic environment – acute categories 2 and 3
The draft does state that the legislation will not apply to radioactive substances, non-isolated intermediates, mixtures for scientific research and development, or veterinary products, cosmetic products, food or feeding products. It will not apply for articles either but can be provided for articles on a voluntary basis.
Gulf Cooperation Council
- Be alert to finalization of the draft and incorporation into national legislation.
- Be prepared to update SDSs and labels in accordance with these new provisions by deadline.
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